Tracking Implementation of the 2025 Reconciliation Law: Medicaid Work Requirements Data and Policies
Detailed state and national data related to the 2025 Reconciliation Law Medicaid Work Requirements
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Detailed state and national data related to the 2025 Reconciliation Law Medicaid Work Requirements
This brief describes new guidance and potential challenges states will face in operationalizing the medical frailty exemption.
A majority of states subject to new Medicaid work requirements — 30 of 44 — will hold gubernatorial elections this November, and leadership transitions, particularly those involving a change in party, could complicate state implementation of work requirements.
On June 1, 2026, the Centers for Medicare and Medicaid Services (CMS) issued an interim final rule on Medicaid work requirements that adopts a restrictive definition of medical frailty—differing from states’ early expectations. The more restrictive definition of medical frailty adopted by the Trump Administration will be challenging for states to implement and could lead to more people falling through the cracks and losing coverage.
This policy watch provides initial insight into how North Carolina is preparing to implement certain Medicaid provisions of the 2025 reconciliation law and how other policy changes may affect coverage and access to care.
This brief describes early state plans to operationalize the medical frailty exemption for Medicaid work requirements and identifies key issues and questions states are facing, some of which may be answered in forthcoming CMS guidance.
In the 39 states that are adopting or may adopt the high unemployment hardship exception, about 1.4 million or 7.5% of Medicaid expansion enrollees live in one of the 133 counties that currently meet the high-unemployment criteria.
KFF hosted a virtual briefing focused on states’ efforts to implement these new Medicaid work and community engagement requirements, which have created new administrative demands on states at a time of federal funding cuts, slowing revenue growth, and increasing spending demands.
The 24th annual survey of state Medicaid and CHIP program officials conducted by KFF and the Georgetown University Center for Children and Families (CCF) provides a baseline of state Medicaid and CHIP eligibility, enrollment, and renewal policies in place as of January 2026 as they prepare to implement the changes included in the 2025 reconciliation law.
A new KFF survey of state Medicaid officials and focus groups in eight states captures the different choices states are making about how to implement Medicaid work requirements, with seven states planning for a more restrictive approach to verifying work or exemption status or to implement work requirements early. These implementation plans are taking shape as states encounter time, cost, and other constraints as well as uncertainty about how to define and verify certain exemptions…
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